SEGA Europe Limited, its subsidiaries and affiliates including Sports Interactive Limited (“SI”) (together “SEGA”, individually a “SEGA Entity”) are committed to protecting the privacy and security of your personal information. SI collects different types of information about you for inclusion in its database relating to the Football Manager (“FM Database”) series of games published on various formats ("Products"), whether you are (i) a consumer and player of our Products or (ii) a football professional including but not limited to a footballer, manager, referee, coach or medical staff member ("Football Professional").
1. INFORMATION WE COLLECT
The FM Database comprises a complex and detailed database which simulates real-world football performance. The FM Database comprises data compiled from and using or representing real-life Football Professionals from around the world. The FM Database includes full names of the Football Professionals as well as characteristics, behaviour and likenesses as they relate to the Football Professional's career in the real world.
Specifically, SEGA collects some or all of the following personal data in respect of each Football Professional:
- Given first name and surname.
- Date of birth.
- Head shot photograph.
- Details about the Football Professional's club, which may include contract type and expiration date, team and game statistics.
- Estimated gross salary, earnings per week and number of bonuses awarded.
- Physical attributes, such as hair colour, height, weight and body type.
- Medical history (limited to injuries or illnesses that prevent a player from playing football for a period of time) where Football Professionals have themselves or through their representatives made such medical history, or allowed it to become, public;
- Various technical, mental and physical attributes.
(together, the “FM Data”).
2. HOW WE COLLECT YOUR INFORMATION
The FM Data is compiled by SI’s scouting network which comprises approximately 1,300 individuals across 50 countries (the “Network”). The Network collects the FM Data in three ways: (i) through attendance at football matches where the performance of Football Professionals is observed and rated; (ii) through publicly available information such as newspapers, match programmes, match reporting websites, general football interest websites and TV programmes; and (iii) through SI’s relationships with various third parties such as football clubs, leagues and football associations.
3. HOW WE USE YOUR INFORMATION
Once the FM Data has been compiled by the Network, SI’s in-house research team review the FM Data and data sources. Subjective sets of ratings which cover physical, mental and technical attributes of Football Professionals are built up over a period of weeks, months and years to provide a full profile. The Network and the research team at SI watch Football Professionals play in matches or in training sessions, read match reports on various types of media, and reference SI’s forums where discussions are to be found on each set of data within each country. Once the FM Data has been verified and cross-referenced by SI’s in-house researchers, it is then integrated within the FM Database to provide customers with a rich and realistic football management experience. As part of this experience, we process all non-sensitive FM Data (which excludes medical history data) for our legitimate commercial interests. We process medical history data on the basis that such information has been made publicly available.
Additionally, Football Professionals are rated by the Network in more than 30 categories based on technical ability (for example: dribbling and corner-taking), mental ability (for example: aggression and decision-making) and physical ability (for example: balance and agility). These ratings are intended to reflect the Football Professional's ability, but SI and SEGA make no guarantee, warranty or representation as to the accuracy of such ratings at any time.
4. WHEN WE SHARE INFORMATION
We may share your personal information with:
- Consumers of our Products. The FM Database powers our Products and as such your personal information is shared with our customers when they access and use our Products.
- Third parties with whom we share your information in order to undertake various activities or services on our behalf in supporting the Products.
- Select third party partners within the sporting world (such as football clubs and data analytics businesses) so that they can use the FM Database to improve youth team development, or to analyse team performance and analytics or for scouting purposes.
- If our business enters into a joint venture, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, or new business partners or owners or their advisors.
- We may use the information that you provide if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or to enforce the relevant terms of service and any other agreement; or to protect our rights or the rights of third parties. This includes exchanging information with other companies and organisations such as credit agencies, law enforcement or government bodies or the courts in connection with a criminal investigation, suspected illegal activity, fraud prevention and detection or in legal proceedings.
Personal information may be transferred to other countries where SEGA or its service providers maintain operations. These countries may not have equivalent data protection laws to the country from where you access the Products or, in the case of transfers subject to European law, may not be subject to an adequacy decision by the European Commission (EC). An adequacy decision is a decision taken by the EC establishing that a third country provides a comparable level of protection of personal data to that in the EU, through its domestic law or its international commitments.
Where SEGA transfers personal information it will seek to take account of any applicable legal obligations relevant to personal information transfers. In the case of transfers of personal information out of the European Economic Area, it will, in the absence of an EC adequacy decision relevant to the destination country, seek to rely on appropriate safeguards such as a valid Privacy Shield certification (in the case of a data transfer to a Privacy Shield certified US recipient - https://www.privacyshield.gov/welcome) or enter into appropriate EC approved standard contractual clauses relevant to personal data transfers between data controllers or between a data controller and a data processor, (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm).
5. SECURITY AND DATA RETENTION
We place great importance on the steps we take, including physical, technical and organisational measures, to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. Your personal information will be retained by us for the duration of the commercial lifetime of our Products and may be retained for a period after this time as necessary and relevant to our legitimate operations, and in accordance with applicable laws and obligations. This may include retention necessary to meet our tax reporting requirements as well as time required to enforce the relevant terms of service, any game “sun-setting” requirements or to identify, issue or resolve legal proceedings.
We may retain a record of your stated objection to the processing of your personal data for the sole purpose of ensuring that we can continue to respect your wishes to not contact you further, during the term of your objection.
We will take appropriate steps to seek to destroy or permanently de-identify personal information at the point this information is no longer needed by us for our business or legal purposes.
For more information about exercising your rights with respect to our data processing activities, see details below about your choices and rights.
6. YOUR CHOICES AND RIGHTS
Whilst SI takes great care to verify the accuracy of the FM Data, and takes stringent security measures to protect such data, Football Professionals have the right to ask us: (i) to amend the FM Data; or (ii) not to process the FM Data within the FM Database. You can exercise your right by contacting SI at the following email address: email@example.com or firstname.lastname@example.org.
We respect the rights you may have under applicable law to request access to your personal information and where applicable, to request to receive that information in a commonly used electronic format (or ask for this information to be provided in that format to a third party where feasible). You may also have the right under applicable law to request the correction or erasure of your personal information, to seek to object to the further processing of your information under certain circumstances or to request that the processing of specific information about you is restricted while we verify or investigate your concerns about this information.
If you remain unhappy with a response you receive, you can also refer the matter to your data protection supervisory authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm )
7. YOUR QUESTIONS AND HOW TO CONTACT US
If you have any questions or comments about this policy or our practices you can contact us:
By email at: email@example.com
By telephone on: +44 870 010 8002
By writing to us at:
SEGA Europe Limited
27 Great West Road
You can also contact our data protection officer at firstname.lastname@example.org.